Is this the first response you've received? If so, yes I would do as you suggest, but also make clear that it has taken them 5 months to issue a 3 paragraph response that neither properly engages with the issues you raised nor complies with the PAPDC.
You don't want to end up in an endless letter ping-pong, but if you can create a clear paper trail that evidences their shoddy conduct this is advantageous.
As ever feel free to show us a draft.
Yes this was the first response!
Planning to respond with the below, although I realised there is no return address and I'm overseas so may just try sending via email again, cc'ing myself.
_____________________
Dear Sirs,
I acknowledge receipt of your letter dated 26 February 2026.
Your response does not properly engage with the matters raised in my previous correspondence and fails to provide the documents specifically requested pursuant to the Pre-Action Protocol for Debt Claims (PAPDC) and the Practice Direction - Pre-Action Conduct and Protocols (PD-PAC).
1. Continuing Protocol Non-Compliance
In my previous correspondence I requested disclosure of key documents required under PAPDC paragraphs 5.1-5.2 and PD-PAC paragraph 6, in order to enable the parties to properly understand the issues in dispute and to comply with the objectives of the pre-action process.
Your response contains none of the requested material and instead consists of a brief assertion that the Parking Charge Notice was correctly issued. Such a response falls materially short of the obligations imposed upon a creditor under the Protocol.
For the avoidance of doubt, the requested documents remain outstanding.
2. Failure to Meaningfully Engage
It is notable that your organisation has taken approximately five months to produce a response comprising only a few paragraphs which neither addresses the substantive issues raised nor provides the documentation required to allow meaningful engagement with the alleged claim.
This conduct does not comply with either the letter or the spirit of the Pre-Action Protocol for Debt Claims or the Practice Direction on Pre-Action Conduct, both of which require parties to exchange sufficient information and documentation to properly narrow or resolve disputes prior to litigation. Your letter dated 26 February 2026 also fails to provide any address for correspondence. This omission further undermines compliance with the Pre-Action Protocol, which requires parties to provide sufficient information to enable meaningful engagement and response prior to the commencement of proceedings.
3. Requested Documentation
The documents previously requested remain outstanding, including but not limited to:
the original Notice to Keeper and all subsequent notices;
strict proof of the legal basis of liability, including compliance with Schedule 4 of the Protection of Freedoms Act 2012 if keeper liability is alleged;
all ANPR images, photographs and VRM logs relating to the alleged incident;
contemporaneous evidence of signage in situ on the material date together with a site plan showing sign locations and entrance signage;
the unredacted landowner contract or chain of authority establishing your standing to offer parking contracts and pursue litigation at the site;
any payment machine records or audit logs relevant to the alleged period; and
a full breakdown of the sum claimed, including the legal basis for any amount above the core parking charge.
Until these documents are provided, it is not possible to properly assess the basis of your claim or provide a substantive response.
4. Reservation of Rights
We reserve the right to bring to the court’s attention, in any proceedings you may commence, your apparent failure to disclose information that is plainly central to your claim. We will further contend that your unreasonable withholding of such material amounts to a deliberate obstruction of the pre-action protocol. In those circumstances, we will seek appropriate costs sanctions against you.
Further, I expressly reserve the right to rely upon your continued non-compliance with the Pre-Action Protocol when addressing case management directions and any costs issues that may arise should proceedings be issued.
5. Protocol Timing
As previously stated, the 30-day response period under the PAPDC cannot properly commence until a compliant Letter Before Claim supported by the requested documentation has been provided.
Should proceedings be issued without compliance with the Protocol, I will invite the court to consider a stay of proceedings to allow proper compliance, together with any appropriate directions and sanctions.
6. Availability
Please note that I will be overseas until mid-April 2026. During this period I will be able to respond only to email correspondence. Any further communication should therefore be sent electronically.
If you intend to pursue this matter, please provide the requested documentation in a single paginated electronic bundle so that the issues may be properly considered.
Yours faithfully,
Keeper
